Portfolio Projector, LLC (“Portfolio Projector,” “we,” “us,” or “our”) values your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your personal information when you visit our website or use our services (collectively, the “Service”). By using the Service, you consent to the practices described in this Privacy Policy.

1. Member Consent

By submitting personal data through the Service or Site, you consent to our collection, use, processing, disclosure and retention of your personal data in accordance with this Privacy Policy and applicable law.

2. A Note about Children

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we discover we have collected personal data from a child, we will delete it promptly.

3. Types of Data We Collect

We collect the following categories of data:

• Personal Data – information that can identify you, such as your name, email address, postal address, phone number, account information, payment information, and IP address. You may provide Personal Data when you register for an account, make purchases, contact us, or otherwise use the Service.
• Usage Data – information about how you interact with the Service, such as pages viewed, date and time of access, device type, browser type, and operating system. We collect this automatically through cookies, web beacons and similar technologies.
• Financial & Investment Data – If you connect financial accounts or manually enter financial information, we collect data including but not limited to: bank account and transaction data (accessed through Plaid, Inc.), brokerage and investment account data, property details, purchase prices, valuations and projected returns, income and expense information, net worth estimates, cash flow projections, and portfolio performance data. This information is used solely to provide the Service and as described in this Privacy Policy. Financial information is treated as sensitive personal information.
• Inferred & Derived Data – We may derive insights and scores from your financial and usage data, such as portfolio risk scores and financial independence projections, as part of our AI-powered analysis features.

4. Cookies and Tracking Technologies

We and our third-party service providers use cookies and similar technologies to enhance your experience, analyze usage patterns and deliver personalized content. You can control cookies through your browser settings, but disabling cookies may limit certain features. We do not respond to “Do Not Track” browser signals at this time. If you use our subscription or checkout pages, our payment processor may place cookies or similar tracking technologies on your device to detect and prevent fraudulent activity and to enable the payment session. These cookies are essential for completing a transaction and may not be disabled without affecting your ability to make payments.

5. How We Use Your Data

We may use your Personal Data, Financial Data, and Usage Data to:

• Provide, maintain and improve the Service;
• Verify your identity and authenticate your account;
• Process payments and transactions;
• Communicate with you regarding your account, customer service requests, updates or promotions (where permitted by law);
• Conduct analytics and research to improve our products and services;
• Detect and prevent fraud or misuse;
• Comply with legal obligations and enforce our Terms of Service;
• For any other purpose with your explicit consent.

AI/ML Model Development. We may use anonymized and aggregated data derived from user interactions to train, improve, and develop our artificial intelligence and machine learning models and features. We do not use individually identifiable Personal Data or individually identifiable Financial Data for AI/ML model training without your separate express consent. You may opt out of your anonymized data being used for AI model development at any time by contacting us at legal@portfolioprojector.com.

We may anonymize or aggregate personal data so that it can no longer identify you. We may use and disclose such aggregated data for any lawful purpose.

6. Payment Processing

We use Stripe, Inc. (“Stripe”) to process subscription payments. When you subscribe or make a payment, the payment information you provide—including your name, billing address and credit-card details—is transmitted directly to Stripe. Stripe acts as a data processor on our behalf and uses your information to process payments, verify your identity, prevent fraud and comply with legal and financial obligations. We do not collect or store your full payment-card number on our systems; we may retain only limited details (such as the last four digits and expiration date) for record-keeping and customer-service purposes. Stripe may collect additional personal data—such as device information, browser data and usage signals—when you interact with our checkout pages. Stripe’s collection and use of your personal data is governed by the Stripe Privacy Policy at stripe.com/privacy.

7. Promotions and Free-Trial Offers

From time to time we may offer promotional programs or free-trial subscriptions. Eligibility is limited to first-time subscribers and cannot be combined with other promotions. Unless we tell you otherwise, at the end of the promotional or trial period, your subscription will automatically convert to a paid plan and the applicable fees will be charged to your payment method. Where required by applicable law, we will send a reminder notice before your free-trial period expires. You may cancel at any time during the trial through your account settings.

8. How We Share Your Data

We do not sell your personal information. We may share Personal Data with:

• Service Providers – third-party vendors who provide services such as hosting, payment processing, data analysis, identity verification, customer support, marketing assistance and security. These providers are contractually obligated to protect your data and use it only for our business purposes.
• Financial Data Integration Provider (Plaid) – If you connect financial accounts to the Service, your financial account credentials and account data are processed by Plaid, Inc. Plaid accesses your financial information on our behalf to enable account integration features. Plaid’s collection and use of your data is governed by Plaid’s End User Privacy Policy, available at plaid.com/legal. You may revoke Plaid’s access at any time through your account settings or directly at my.plaid.com.
• Affiliates and Partners – subsidiaries or affiliated companies under common control, provided they adhere to this Privacy Policy.
• Business Transfers – in the event of a merger, acquisition, sale or restructuring, your data may be transferred as part of the transaction. We will provide notice via email and a prominent posting on our website at least thirty (30) days before your data becomes subject to a materially different privacy policy.
• Legal Requirements – when required by law, subpoena, or other legal processes, or to protect our rights, property and safety or that of our users or others.
• With Your Consent – we may share your data for purposes disclosed at the time of collection or with your consent.

9. Data Retention

We retain different categories of personal information for different periods based on legal and business requirements:

• Account information: Retained for the duration of your account plus three (3) years after account closure.
• Financial and portfolio data: Retained for the duration of your account plus seven (7) years to comply with applicable tax and financial record-keeping requirements.
• Payment records: Retained for seven (7) years to comply with financial regulations.
• Usage and analytics data: Retained for twenty-four (24) months.
• Marketing communications data: Retained until you opt out or request deletion.

When data is no longer required for the purposes for which it was collected, we securely delete or irreversibly anonymize it.

10. Your Rights and Choices

Depending on your jurisdiction, you may have rights to access, correct, delete, port, or restrict the processing of your Personal Data. To exercise these rights:

• Submit a request to legal@portfolioprojector.com with “Privacy Rights Request” in the subject line;
• Include your full name and the email address associated with your account;
• Describe the right you wish to exercise and the data involved.

We will verify your identity before processing your request. We will respond within forty-five (45) days of receiving a verifiable request; we may extend this by an additional forty-five (45) days for complex requests, with written notice of the extension. You may opt out of marketing communications at any time using the unsubscribe link in any marketing email.

10a. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, our business purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete. You may request deletion of your personal information, subject to certain legal exceptions.
• Right to Correct. You may request correction of inaccurate personal information we hold about you.
• Right to Limit Use of Sensitive Personal Information. You may direct us to limit our use of sensitive personal information — including financial data — to uses necessary to provide the Service.
• Right to Opt-Out of Sale/Sharing. We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising without your consent.
• Right to Non-Discrimination. We will not discriminate against you for exercising your privacy rights.

To submit a California rights request, contact us at legal@portfolioprojector.com or by mail at Portfolio Projector LLC, PO Box 93, Farmington, MI 48332. We will respond within forty-five (45) days of receiving a verifiable consumer request.

Categories of Personal Information Collected. In the past 12 months we have collected the following CCPA categories: Identifiers; Personal information categories listed in the California Customer Records statute; Internet or other electronic network activity information; Financial information; Inferences drawn from personal information.

11. Security Measures

We implement reasonable administrative, technical and physical safeguards to protect your Personal Data, including encryption of data in transit (TLS/SSL) and at rest, access controls limiting data access to authorized personnel, and regular security assessments. However, no method of transmission over the Internet or electronic storage is entirely secure, and we cannot guarantee absolute security. You are also responsible for maintaining the security of your account credentials.

11a. Data Breach Notification

In the event of a security incident involving unauthorized access to, disclosure of, or loss of your personal information, we will:

• Notify you via email to the address associated with your account as soon as reasonably practicable;
• Notify relevant regulatory authorities as required by applicable law;
• Provide you with a description of the nature of the breach, the categories of personal information affected, the steps we are taking to address it, and recommended steps you can take to protect yourself.

We will endeavor to provide notification within the timeframe required by applicable law and in no event later than sixty (60) days after confirmation of a breach affecting your personal information.

12. International Transfers

Portfolio Projector is located in the United States. If you access the Service from outside the U.S., your information may be transferred to, stored and processed in the U.S. Data protection laws in the U.S. may differ from those in your country. For transfers of personal data from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States, we rely on approved transfer mechanisms including Standard Contractual Clauses (SCCs) as adopted by the European Commission and/or the EU-U.S. Data Privacy Framework (DPF) where applicable. You may request a copy of the applicable transfer safeguards by contacting us at legal@portfolioprojector.com.

13. Biometric Information

We do not currently collect biometric information (such as facial recognition or fingerprint data) as part of our standard Service. If we introduce features that collect biometric data in the future, we will provide clear, specific notice and obtain your explicit consent before any collection, use such data solely for the disclosed purpose, retain biometric data only as long as needed, and update this Privacy Policy accordingly.

14. Third-Party Sites

The Service may contain links to third-party websites. We do not control and are not responsible for third-party privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will post any changes on our website with an updated “Last Updated” date. For changes that materially affect how we collect, use, or share your data, we will provide advance notice by email to the address associated with your account before those changes take effect. Your continued use of the Service after the effective date of any changes constitutes acceptance of the revised policy.

16. Contact Us

If you have questions, complaints, or requests regarding this Privacy Policy or our data practices, please contact our Privacy Team: